Imson vs. People
G.R. No. 193003 (July 13, 2011)
Facts:
On January 24, 2003, at approximately 9:30 PM, a confidential informant reported to the District Drug Enforcement Unit in Caloocan City that Francisco Imson was selling shabu (methamphetamine) at Raja Matanda Street, San Roque, Navotas. Acting on this information, the unit's chief, P/Supt. Reynaldo Orante, organized a buy-bust operation, designating PO1 Gerry Pajares as the poseur buyer. The team, including PO1 Noli Pineda and other officers, arrived at the location around 10:30 PM and observed Imson conversing with Rolando Dayao. They witnessed Imson handing Dayao a transparent plastic sachet containing a white crystalline substance.
Upon identifying themselves, Pajares apprehended Imson while Pineda pursued Dayao, who attempted to flee. The police confiscated two plastic sachets containing suspected shabu from the two men. Imson and Dayao were taken to the Langaray Police Station, where they provided joint sworn statements. The sachets were marked by PO1 Ariosto B. Rana and sent to the Philippine National Police - Northern Police Crime Laboratory for examination, which confirmed the presence of shabu.
On January 27, 2003, Third Assistant State Prosecutor Marcos filed two informations for illegal possession of dangerous drugs against Imson and Dayao.
Legal Issues:
The primary legal issue in this case revolves around the admissibility of the seized evidence (the plastic sachets containing shabu) based on the alleged failure of the police to comply with the procedural requirements set forth in Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002), particularly regarding the chain of custody of the seized items.
Arguments:
Petitioner's Argument (Imson and Dayao):
- The defense contended that the two plastic sachets were inadmissible as evidence due to procedural lapses by the police. They argued that the police failed to conduct a physical inventory, photograph the seized items in the presence of the accused or their representatives, and mark the sachets at the site of the arrest. These failures, they claimed, cast doubt on the integrity of the chain of custody and the legitimacy of the buy-bust operation.
Respondent's Argument (People of the Philippines):
- The prosecution maintained that despite the alleged procedural lapses, the integrity and evidentiary value of the seized items were preserved. They argued that the failure to comply with the inventory and photographing requirements did not invalidate the buy-bust operation or the admissibility of the evidence, as long as the chain of custody was established and the items were proven to be the same as those seized.
Court's Decision and Legal Reasoning:
The Court affirmed the decisions of the Regional Trial Court and the Court of Appeals, finding no merit in the petitioners' arguments. The Court held that the procedural lapses cited by the defense did not render the seized items inadmissible. It emphasized that non-compliance with the requirements of Section 21 of RA 9165 is not fatal to the prosecution's case, provided that the integrity and evidentiary value of the seized items are preserved.
The Court referenced previous jurisprudence, including People v. Bralaan and People v. Pringas, which established that the failure to conduct a physical inventory or photograph the seized items does not automatically impair the chain of custody. The Court noted that the presumption exists that police officers perform their duties regularly, and the burden lies on the accused to prove bad faith or improper motive on the part of the police, which Imson failed to do.
The Court concluded that the prosecution successfully established an unbroken chain of custody for the seized drugs, affirming the lower courts' findings of guilt beyond reasonable doubt for illegal possession of dangerous drugs.
Significant Legal Principles Established:
Chain of Custody: The integrity of the chain of custody is crucial in drug-related cases, but minor procedural lapses do not necessarily invalidate the evidence if the integrity of the items is preserved.
Presumption of Regularity: There is a presumption that police officers perform their duties in good faith, and the burden of proof lies on the accused to demonstrate any misconduct or tampering.
Non-fatal Procedural Lapses: Non-compliance with procedural requirements under RA 9165, such as inventory and photographing of seized items, is not fatal to the prosecution's case as long as the integrity of the evidence is maintained.